Although we welcome the feedback and dialogue, we are discouraged that Mr. Murray’s comment addresses none of the substantive points raised by the Synapse report (PDF) or my post discussing the report. We are disappointed as well that the comment dismisses the fundamental need identified by the Synapse report – an honest and credible accounting for the effect of new imports on overall greenhouse gas emissions. Instead of working on providing such an accounting and engaging in a real dialogue about this issue, Northern Pass Transmission LLC (NPT) has invested heavily in advertising for the Northern Pass project, including the promotion of an emissions reductions figure reliant on new reservoirs that is based on an erroneous zero-emissions assumption. That assumption is contradicted by the Synapse report and Hydro-Québec’s own research, and the marketing claims on this issue (see, for example, here) are thus false and misleading and should be withdrawn immediately, as we have requested in a separate communication to NPT.

The citation to the Climate Action Plan sidesteps the merits of the emissions reduction issue entirely:

First, the Task Force did not have the information in the Synapse report at its disposal in making its recommendations.

Second, the Climate Action Plan contains important qualifications on its import recommendation that NPT does not acknowledge. The recommendation itself contains the proviso that new imports should be pursued “with consideration for the broader environmental impacts of the power sources as well as the impacts that this imported power would have on the development of in‐state renewable resources.” That consideration is the work CLF believe needs to happen but has not. In this regard, NPT’s dismissal of all questions or “challenges” on these issues is flatly inconsistent with the Climate Action Plan’s recommendation.

Third, the Climate Action Plan appendix discussing the recommendation (PDF) states that “[t]he benefits to electric customers would be determined by the specific terms of any purchased power agreement and the reductions to New England fossil fuel generation which would be subject to state regulatory review and confirmation at the time of any filings for state approval.” (p. 29) In other words, the economic and environmental benefits from imports depend on the details of the proposal, specifically the terms and what generation is displaced. Yet the current proposal includes no Power Purchase Agreement that would benefit PSNH’s own energy consumers, assumes that any future power purchase agreement will be for only a small amount of power, and provides no guarantee or commitment that the imported power will reduce emissions in a meaningful way. The Synapse report directly refutes the only analysis of emissions reductions that NPT has made publicly available. The Climate Action Plan underscores the fundamental need for imports to provide real environmental and economic benefits for New Hampshire, and the current proposal on the table does virtually nothing to meet that need.

Fourth, unlike all other recommendations in the Plan, enabling importation of Canadian hydro received a number of “no” votes from the Task Force, “due to concerns over the potential environmental impacts of the imported power and the effect imported power might have on development of in-state renewable resources.” Public comments from a number of stakeholders, including CLF, questioned the entire recommendation based on these concerns. (Comments are summarized at pp. 246-258 of this PDF.) There was a debate then, and that debate should continue now, based on well-sourced and credible information like the Synapse report.

We agree that there is no one single solution to the climate challenge. But any serious effort to confront climate change in New Hampshire must also confront the largest source of greenhouse gas emissions in the state – PSNH’s aging, inefficient, and uneconomic fossil fuel power plants. As Dr. Tremblay of Hydro-Québec admitted, in comments that NPT is now approvingly citing, “the major environmental challenge facing North America is to replace coal to generate power….” CLF couldn’t agree more.

It seems NPT and its affiliates do not agree with Dr. Tremblay. Importing an additional 1,200 megawatts of hydropower from Canada will not help move New England toward a clean energy future if, as the current proposal is structured and as PSNH has repeatedly claimed, imports would only displace relatively clean natural gas generation, and not the power plants that are worst for the climate, like PSNH’s coal-fired units at Merrimack and Schiller Stations.